October 20, 2016
Attention: Mr. Roak Parker,
DOE Golden Field Office
15013 Denver West Parkway
Golden, CO 80401
C.c. Mr. Matt Butler, OPSB, Senator Bill Seitz, Governor John Kasich, James Zehringer, OHIO DNR, Andrew Cornacki, USACE, Joseph Krawczyk, USACE
Dear Mr. Parker and DOE Staff,
Re: “ICEBREAKER” PROJECT TITLE EA-2045
I’m contacting you with my scoping comments regarding the Icebreaker offshore wind project being proposed for Lake Erie. It is my understanding that DOE wishes our comments to relate to environmental issues and I’ll try to accommodate this goal.
Potential Environmental Risks
- Seabed sediments
- Marine and coastal processes
- Seabed contamination
- Water quality
- Protected sites and species
- Benthic ecology
- Fish and shellfish/ Fisheries
- Marine birds
- Marine mammals
- Installing the turbines in the lake, churning the lake bottom
- The Icebreaker 6-turbine project is only the beginning
- Turbine foundation design & concept proposed is completely untested in freshwater ice
Ice will contribute to lake contamination as the shear of ice along with the combined action of waves and wind will eventually topple the turbines and foundations causing the hundreds of gallons of fluids inside the nacelles to drain into the lake. The proposed mono bucket turbine foundations are not fastened fast to bedrock but simply sitting on the mud at the bottom of the lake waiting for an accident to occur. How long can such an assembly of foundation, tower, nacelle, rotating blades stay within installed to within 0.1 degree of true vertical on a muddy lake bottom? The drawing of the mono bucket foundation designed by Universal Foundation (a Fred Olsen company) is below. Do you have faith this design will work successfully without eventually toppling over mainly as a result of wind, wave and ice action? How would any effort be made to deal with a topple disaster during winter or when heavy ice is present? No offshore turbine foundation design has ever been subjected to freshwater ice conditions anywhere! Let’s not make the Great Lakes and Lake Erie the guinea pig in this experiment.
The view below shows the mono bucket design by Universal Foundation resting in the lake bottom (seabed). The blue square is the lake surface and the brown area is where the bucket is supposed to be where the foundation sinks into the lake bottom. The Vestas V126-3 (3.45Mw) wind turbine mounts on top of the foundation making the entire assembly extremely top heavy with no solid structure supports holding the assembly to the bedrock – a very risky design. The second drawing shows the foundation having the water and mud sucked out supposedly holding the foundation and entire tower permanently square with the earth and unable to tip over while resisting wind, wave action and other forces acting on this assembly.
The National Renewable Energy Laboratory (NREL) said in their ASSESSMENT OF OPPORTUNITIES AND BARRIERS September 2010 report: The lakes contain freshwater, and surface ice floes will be a major design driver for any offshore turbines (Barker and Timco 2006; Määttänen 2002).
Per Lake Erie Waterkeeper (http://www.lakeeriewaterkeeper.org/lake-erie/facts/) Lake Erie has a retention/replacement time of 2.6 years which is the shortest of the Great Lakes, provides drinking water to over 11 million people and is the twelfth largest lake in the world (in area), and its border includes four states (New York, Pennsylvania, Ohio, and Michigan) and one Canadian Province (Ontario).Lake Erie, a freshwater lake, also freezes completely solid from Ohio to Ontario, Canada many years. The NOAA provided photo below was published in the NY DAILY NEWS, Tuesday, February 17, 2015 showing frozen Lake Erie.
The Daily News story also mentioned: While 100% ice cover for Lake Erie is rare, it’s not unprecedented. The water was fully covered in 1978, 1979 and 1996, too.
A review of surface engineering issues critical to wind turbine performance covers many ice accretion issues the Icebreaker turbines will surely face. Ice may cause full stop of the turbine, decreased fatigue life, human safety risks, as well as ice affecting the foundation itself. Ice build up on the rotor blades will create an out-of-balance condition.
As a result of the development of this project, Lake Erie drinking water is destined to become polluted soon just like Toledo, Ohio and Flint, Michigan. The polluter is dubbed the “Icebreaker”, a Lake Erie offshore wind turbine pilot project, 6 turbines, 8 miles offshore from Cleveland, the brainchild of Cleveland Foundation CEO Ron Richard who is also board chairman of the Lake Erie Energy Development Corp., (LEEDCo) the original project developer. (Please note that at the time of these comments I am not sure who the owner or developer is for the Icebreaker project as the Icebreaker assets are being sold from Cleveland’s Lake Erie Energy Development Corporation to Fred Olsen Renewables – a Norwegian company). I have learned today (Oct. 18, 2016) that Leedco has withdrawn their application for this Icebreaker project from the Ohio Power Siting Board on Sept. 13, 2016. I do not know what Leedco’s involvement is in the Icebreaker project at this point in time. I have a feeling OPSB failed to relay this info to DOE.
Polluting the drinking water will be accomplished by churning up the toxin laden Lake Erie lake bed while siting the 6 turbine foundations. Water, mud and toxins will be pumped from the inside of each turbine mono bucket foundation and eventually find its way back into Lake Erie while the turbine foundation settles into the lake bottom as a result of the pumping action and gross weight of the foundation itself. The pumping action will discharge tons of sediments from the lake bottom including noxious substances which will pollute Lake Erie waters.
The lake bed will be churned up again with a jet plow or similar underwater devices to lay and bury miles of turbine to turbine electrical and communications cables further polluting the lake with toxins. And eventually the cables will need to be laid from the project site underwater to a substation and on shore – churning up the lake bottom again for miles and resuspending harmful chemicals and metals to pollute the water again including drinking water. The contaminants that have lain dormant at the lake bottom for decades will eventually be sucked into the drinking water crib north of Cleveland. The intake crib is in the lake between Cleveland and the Icebreaker turbines, and is critical to city’s water system. Leedco admits, on their website, sediment can be disturbed during construction and that’s an understatement.
But this isn’t the worst of it – the Icebreaker is merely a pilot or demonstration project leading to the siting of 1,000+ additional turbines in the lake (by Leedco’s own admission), USA side, before 2020. Think about how many cubic yards of noxious substances will be disturbed, suspended in the water and find their way into the water systems of Cleveland and other northern Ohio cities that depend on clean Lake Erie water. Canadians will be affected too and so will Pennsylvania and New York cities. This horrible project is now being sold to foreigner Fred Olsen Renewables along with a US taxpayer grant gift of $40m as Leedco bails out after flogging this despicable project for years while squandering $millions in public and private money. Icebreaker Windpower, Inc., is the new Ohio corporation created by Norway-based Fred Olsen Renewables that will now be developing the 6-turbine Icebreaker project. The DOE should protect the public’s water supply and end this debacle now and protect the water supply before it’s too late.
This project could also impact our Canadian neighbor’s drinking water too – it’s unavoidable. And the water contamination may be swept over Niagara Falls and into Lake Ontario affecting even more people. But the real serious problems won’t begin until Ohio, and possibly other states, can’t resist joining the offshore wind scam and then you’ll have hundreds or even thousands of wind turbines being installed in Lake Erie and creating a monumental drinking water disaster that might take years to recover after making people sick. In 2011 the Province of Ontario enacted a moratorium to prevent installation of offshore wind in the Great Lakes and the moratorium is still in effect today. Ontario wisely took this action to study impacts to the lakes by offshore wind turbines. But what good will Ontario’s moratorium do if the US allows wind energy to contaminate and pollute the Great Lakes?
What person, by name, and by organization, would risk contamination of Lake Erie drinking water by recommending approval of this Icebreaker project? The western end of Lake Erie is already heavily polluted with blue-green algae caused by man-made actions. Please see the sickening result in the photo below of Lake Erie.
Contamination of the lake due to pressure washing of the turbine blades and the resulting wastewater discharge would violate water quality standards. Pressure washing of turbine blades is standard management procedure required perhaps twice yearly as recommended by Vestas – cleaning the turbine blades makes them more efficient.
The future Lake Erie pollution debacle
The Icebreaker project will use Vestas 3.4 Mw direct-drive turbines per their web site – these are foreign made turbines. A Leedco handout card says “…a 1,500 MW target by 2025”. Dividing 1,500 Mw by 3.4 Mw means 500 offshore turbines for Lake Erie on the US side of course – and this is just the beginning. The Leedco web site also says: “…the National Renewable Energy Laboratory indicating there is 46,000 MW of potential in Lake Erie…” Now divide the potential (46,000Mw) by the turbine output (3.4Mw) and you have the number of possible turbines that could be installed in Lake Erie in the future (13,529 turbines) with NREL’s thinking – is this possibility somehow acceptable? Can you imagine the lake pollution that might occur if this should happen? Is this good stewardship of Lake Erie by Ohio? Leedco’s goal is not simply a 6-turbine project but a project that will eventually populate the lake with hundreds (or thousands) of turbines and massively polluting the lake in the process.
There is also severe aesthetic pollution brought by this Icebreaker project because we are looking at the industrialization of Lake Erie. The Icebreaker is NOT a wind farm – it is a wind factory as there is nothing pastoral, bucolic or agrarian about this thievery of the lake views and replaced by industrial machines. The public’s view and use of Lake Erie for recreation and business cannot be monopolized by this unwanted and unneeded wind energy project. Allowing the Icebreaker to steal the public’s fabulous lake view and compelling them to view this visual industrial pollution is unthinkable. Annoying red flashing lights at night on top of turbines (loss of darkness) are another form of visual aesthetic pollution and this condition is worse in foggy weather over the lake.
To permit this visual aesthetic pollution is an abdication of public trust. Ohio is a Public Trust state and the Icebreaker project will eventually have to face a major legal quandary – the Public Trust Doctrine. Is funding in the Icebreaker budget for this consequence?
Pollution of the lake from wind turbines on fire from lightning strikes is another potential disaster. Lake Erie is known for heavy lightning particularly in the northern part of the lake. When turbines start on fire the fire cannot be fought and the debris falls downward and all is burned. For an offshore turbine this means the flaming debris would fall into the lake, including the nacelle, rotor blades and all the fluids within the nacelle – and pollute the lake. Rotor blades burn and there are numerous photos of this on the internet. The mammoth blades are made of a carbon fiber composite, the only known product durable and lightweight enough for turbine use. However, blades are too toxic to be incinerated or recycled. In Denmark, with 6,000 aging turbines, thus 18,000 blades, and no plan for disposing of them, a 2011 article in Denmark’s leading business journal reported, “There exists no solution”.
The US Army Corps of Engineers says they are concerned over avian/bat impact; ice concerns; acoustics to aquatic species and they have not yet commented on the Icebreaker project. USACE is an important player in this dilemma and they have yet to render an opinion and their decision could stop this project cold. A March 2014 Fact Sheet published by the Buffalo District USACE says this in part:
Issues General: Permitting issues for the Corps will be complex and include potential impacts to both local and migratory avian/bat species, difficulties due to ice flows and currents, impacts to air traffic/radar capabilities, acoustic disturbances to aquatic species, potential shipping disruptions and aesthetic concerns for on shore residents. The greatest unknowns currently include potential avian/bat impacts, potential impacts to historic viewsheds, ice concerns, and potential acoustic impacts to aquatic species. This project may require a Corps real estate license and will require a Section 408 permit, as the applicant proposes boring beneath a federal break-wall, federal channel, and confined disposal facility.
The Ohio Power Siting Board denied the Leedco’s application for the Icebreaker project in April 2014. Leedco has not filed a new application since. The board’s denial letter lists 14 concerns, mostly focused on the site of the turbines, the noise they generate and their potential to harm wildlife. What has Leedco done to alleviate the OPSB’s concerns? And now that the project is apparently going to be taken over by a foreign owner – is the new owner even aware of what the OPSB rejected in 2014? As I’ve mentioned this to DOE before – the OPSB mistakenly said on their web site that the DOE Cleveland Sept. 28, 2016 “meeting” intended for the public was cancelled – when it was not. The meeting was also NOT legally noticed. I believe the OPSB indicated the DOE meeting was cancelled was because the OPSB received a Sept 13, 2016 dated letter from Leedco’s attorneys that said in part: “Lake Erie Energy Development Corporation (LEEDCo or Applicant) requests to withdraw its application for a certificate to construct Project Icebreaker, a wind-powered electric generation facility, which was filed in this docket on February 7, 2014“. I can’t help but wonder if OPSB ever shared this information with DOE?
Leedco has hardly mentioned decommissioning the Icebreaker. Decommissioning turbines is an important and costly task. The word is not in Leedco’s vocabulary nor is the cost for this task which would be substantial. Decommissioning is was never mentioned by Leedco in the DOE $40+ grant application either. What’s the cost of decommissioning 6 offshore turbines and related apparatus? It’s my guess that the developer will seek to take the easy way out and simply knock the turbines over in the lake and leave the debris there forever to pollute the lake for decades. Removing (hundreds or thousands) from the lake is like polluting the lake a second time – just the same as when the turbines were installed. This environmental end is unacceptable.
Despite LEEDCo saying the opposite – the US Coast Guard said they will not provide icebreaker service for the Icebreaker. (I have this in writing from the US Coast Guard in Cleveland)
Leedco’s CEO Lorry Wagner said in a phone call to a Great Lakes Wind Truth member, Suzanne Albright, that one of the main goals of the wind project is to reduce coal usage that would in turn reduce the amount of mercury entering Lake Erie. Ramping up and down of coal electric plants to suit wind energy will actually increase CO2 pollution. Coal usage was mentioned only once before by a Mr. Nash, a lawyer and legal consultant to Leedco. Leedco’s Wagner told Albright the motivation for Icebreaker is significantly different than that of New York Power Authority’s Great Lakes Offshore Wind (GLOW) project, that Leedco’s main purpose is to save Lake Erie and Ohioans from the millions of tons of mercury going into the lake from coal power. We cannot find data that supports Wagner’s claim that there’s 3 times the amount of mercury in Lake Erie as there is in Lake Ontario but perhaps it’s true. In any case, wind energy always needs backup for its hopeless intermittency and the backup is likely to be polluting fossil fuel generated – in Ohio probably coal – and that backup will continue to indirectly pollute Lake Erie.
Another environmental catastrophe is the avian issues. I mention this briefly because others submitting comments to DOE will get into this area much deeper. Much of the Curry/Kerlinger October 2013 avian report is based on much earlier data and studies. Kerlinger down plays much of what is harmful to bird life and is known to be hired by developers seeking results that are questionable and favor the wind industry. What’s important is this report was heavily criticized by USFW and the Ohio DNR.
The Icebreaker project is illegal due to the Migratory Bird Treaty Act. The Migratory Bird Treaty Act is a Federal law that carries out the United States’ commitment to four international conventions with Canada, Japan, Mexico and Russia. Those conventions protect birds that migrate across international borders.
In the fall of 2013, in a culmination of all the previous work conducted, Curry &. Kerlinger released Avian and Bat Risk Assessments, finding that the six turbine demonstration-scale project will have no significant impact on avian and bat populations and no impact to Threatened & Endangered (“T&E”) species. This is unbelievable!
The US Army Corps of Engineers says they are concerned over avian/bat impact; ice concerns; acoustics to aquatic species and they have not yet formally commented on the Icebreaker project. USACE is an important player in this dilemma and they have yet to render an opinion and their decision could stop this project cold.
Noise pollution – People’s health will be affected by infrasound which dissipates very slowly, especially over water. People may not hear 6 offshore Icebreaker turbines but how could you possibly not hear hundreds of them when this project ramps up in a few years and hundreds are operating 23/7? There is possible noise pollution from turbine foghorns and maintenance equipment (helicopters).
We are concerned that if any offshore turbines are allowed to be sited in Lake Erie – the same Great Lakes industrialization with wind turbines will soon follow in all the other Great Lakes along with the pollution and environmental harm. All this for wind projects that might operate 25% of the time for maybe 15 years.
Now consider the Ohio Lake Erie Commission 2008 Lake Erie restoration plan priority goals: Practice and promote sustainable practices that protect the natural resources of the Lake Erie basin and make them available for current generations to enjoy. Ensure that urban areas are sustainable, minimize impacts to the Lake Erie ecosystem, and improve the quality of life within watershed communities. Responsibly utilize Lake Erie resources and maximize recreational opportunities. Does the Icebreaker do this?
We don’t want Lake Erie to eventually look like the view below.
(Editor’s Note: Please imagine that in 10-15 years, the likely non-existent decommissioning, or wear and tear breakdowns, will need to be re mediated. Imagine the cost, imagine the ugliness, and the environmental blight. This is not long term thinking!)
(Please note that this is similar to but not the original picture in Mr. Isselhard’s letter to the DOE)
Wolcott, NY 14590
Founding Member: Great Lakes Wind Truth